08.11.2016 Virginia DEQ to Revise Risk Assessment Protocols
The Virginia Department of Environmental Quality (“DEQ”) is preparing to implement revised risk assessment protocols for many of its site cleanup programs. DEQ’s new approach is called the Virginia Unified Risk Assessment Model (“VURAM”), and affected programs include the Voluntary Remediation Program, the RCRA Corrective Action Program (for hazardous waste sites), and solid waste cleanup programs.
Those who have conducted cleanups in Virginia (and most other places) have encountered the often complex and, in some cases, rather subjective process necessary to determine risks to human health and the environment posed by hazardous substances. These risks regularly drive key aspects of site cleanup remedies, including where and to what extent cleanup must occur. While risk assessments can present substantial hurdles for cleanup and redevelopment of property, they can also be used to demonstrate that significant and expensive remediation is unnecessary if institutional and engineering controls are used. Control measures can include such things as site design, constructed and installed measures, and restrictive covenants. Commonly used restrictive covenants limit construction and utility worker exposure as well as use of groundwater or use of the property for residential purposes. Of course, the cost to implement these control measures will affect the budget of any redevelopment project, but the investment made is often far less than the cost to perform a full cleanup.
VURAM is a risk assessment calculation tool that will replace the Voluntary Remediation Program calculation tables, as well as replace the risk assessment portion of DEQ’s long-used REAMS software. As with DEQ’s current risk assessment practices, VURAM will evaluate both carcinogenic and noncarcinogenic risks and account for factors such as applicable regulatory program requirements, relevant contaminants of concern, affected or threatened environmental media (i.e., soil, groundwater, surface water or indoor air), and potential human and ecological receptors. DEQ believes VURAM will help streamline the risk assessment process while providing risk assessment outputs for specific pollutants, impacted media, and site-wide conditions. VURAM will be accompanied by a User Guide that must be consulted when installing and using the tool.
DEQ plans to launch VURAM and the User Guide in September 2016. The agency also has indicated that it is likely to offer training sessions at that time on how to use the new software. Unfortunately, the initial version of VURAM will not include a site screening level risk assessment module; incorporation of that module into VURAM is planned for the spring of 2017. Technical questions about VURAM should be directed to April Ni’Mary at DEQ at 804-698-4534.